Subject: File No. S7-07-13
From: Michael R.K. Mudd
Affiliation: Asia Policy Partners LLC

November 3, 2013

Dear Securities and Exchange Commission:

I am an international investor in publicly traded US companies through my retirement plan.

I strongly support the SEC’s proposal requiring companies to disclose the CEO-to-median worker pay ratio, as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act.

Pay ratio disclosure will help investors evaluate CEO pay and benefit levels (including use of corporate jets, cars, condos, boats, golf clubs, etc ) levels when voting on executive compensation matters. The ratio of the CEO-to-worker pay is a valuable metric for investors, because it places CEO pay levels into a broader perspective.

For example, investors may use pay ratios as a factor when casting say-on-pay votes. Pay ratio disclosure also will help investors better understand their company’s overall compensation for all employees.

High CEO-to-worker pay ratios can have a negative impact on employee morale and productivity. Peter Drucker proposed in the 1980's as these numbers started to rise that the CEO average employee ratio should be capped at 20 to 1 otherwise resentment steps in.

There must be a lot of resentment by now.

Disclosure of the pay ratios will help the capital markets better allocate capital to those companies that invest in their workforces.


Michael R K Mudd MHKCS | Managing Partner | Asia Policy Partners LLC

3208 Central Plaza, 18 Harbour Road, Hong Kong SAR, China